This statement is made pursuant to the Modern Slavery Act 2015 (the “MSA”). It sets out what SGS United Kingdom has done to ensure that slavery and human trafficking is not taking place in its supply chains or in any part of its business.
Group Structure, Business and Suppliers
The ultimate parent company of SGS United Kingdom is SGS SA, a company incorporated in Switzerland. SGS SA heads a global operation helping to ensure product and systems quality and integrity by means of independent testing, inspection, verification and certification services in addition to the provision of employment agency services. In 2017, SGS SA established a Human Rights Committee within its Group Senior Management which oversees compliance with Human Rights in all affiliates of the SGS Group, including SGS United Kingdom, designs and implements Group policies. The SGS Group has implemented a Human Rights Policy, publicly available on its website, which mandates SGS affiliates to assess risks, select and control suppliers and business partners.
SGS United Kingdom procures various property, equipment, consumables and utilities for the provision of its services. It also purchases manpower through subcontracts.
SGS United Kingdom has undertaken a review of our existing systems to ensure compliance with the MSA. This includes consideration of our current policies and existing supplier onboarding process.
Legal and Compliance Policies
For many years the SGS Group has operated under a Code of Integrity applicable to all employees, consultants, joint-venture partners, agents, subcontractors and anyone acting on behalf of, or representing, SGS. This Code contains a prohibition of child labour or forced labour as follows:
“SGS does not use suppliers or subcontractors who use forced labour or child labour and uses reasonable due diligence and monitoring to ensure that suppliers and subcontractors comply with this requirement.”
New employees are trained in the Code of Integrity upon joining SGS United Kingdom and undertake an annual refresher course. Suppliers such as subcontractors, agents and joint venture partners are asked to adhere to the Code of Integrity when they contract with us.
The SGS Code of Integrity is prominently displayed on our website and intranet, where violations can be reported without reprisal.
Having recognised that we rely on our suppliers, and yet we do not have direct control over their impact upon people and the environment, in 2016 a Supplier Code of Conduct was developed. This sets out the standards that SGS expects all suppliers to maintain and has a specific section in relation to People which sets out SGS’s requirement that:
“all work must be voluntary and workers shall be free to leave work or terminate their employment with reasonable notice. The supplier shall not traffic in persons or use any form of slave, forced, bonded, indentured, or prison labour. The supplier shall ensure that third-party agencies providing workers are compliant with the provisions of the Code”.
SGS United Kingdom has commenced a programme to require all suppliers to commit to its principles./
Due Diligence Processes, Areas of Risk and Management, Training
The changes SGS undertook to initiate include:
- Refining our procurement/due diligence process by requiring further information about each supplier to enable us to give each an ethical risk rating. The rating given will dictate how often we review that supplier and the depth of the review required to properly monitor compliance with the MSA
- Initially focusing the new procurement requirements upon our top 50 suppliers by spend (regardless of whether these suppliers were due for their four year review). This equates to 37% of our supply chain spend in 2016
- Targeting operationally critical new suppliers as part of the supplier approval process for receipt of a new supplier questionnaire
- Asking all new suppliers to commit to our Supplier Code of Conduct and reserving the right to terminate contracts in the event of breach
- Helping staff to understand and identify modern slavery risks through knowledge sharing in internal communications
- Addition to compulsory annual Code of Integrity training for 2017
- Providing tailored training to our staff within our manpower services business line as this is theoretically a higher risk with regard to MSA violations
Effectiveness of Our MSA Initiatives
SGS United Kingdom has not detected any violations of the MSA within our supply chain to date and shall continue to review suppliers to minimise the risk of the same. We shall report on the progress of all MSA initiatives in our Modern Slavery Statement next year.
June 2017
This Statement has been approved by the Board of Directors of SGS United Kingdom
On behalf of the Board, Pauline Earl, Managing Director of SGS United Kingdom